Writ of summons - Van Diepen Van der Kroef

statements put in the proceedings as Exhibits 1 through 11, and as will also be shownbelow, there was, however, every reason to do so. The description of war crimes in theNIOD Report, the war crimes observed by the UNMOs, the war crimes observed by theMSF (Médecins Sans Frontières) and the war crimes to which Plaintiff is a witness orwas present, will be discussed below in order.I.11.Observed war crimesDescription of war crimes in the NIOD Report212. The only official report of murder in the Safe Area is found in the report of nine or tencorpses and a possible execution on 13 July 1995. Karremans has always maintainedthat these were the only reports that reached him from the battalion (see page 2656 of theNIOD Report). It can be cited that photographs of the above nine or ten corpses weretaken by a Dutchbat officer, with the result that the report could not be denied. Thedeveloping of the film roll concerned in the film laboratory of the Dutch MilitaryIntelligence Service (MID) was subsequently unsuccessful (see page 392 et seq. of theSummary of the NIOD Report), which exceeds the powers of imagination of Plaintiff.213. It follows from everything that is described in the NIOD Report that Dutchbat witnessedmany more war crimes, which in accordance with Standing Operating Procedure 208– which we repeat – should have been reported. The Yugoslavia Tribunal proceeded onthe basis of witness statements that between 11 and 13 July 1995 at least eighty men andpossibly even a couple of hundred were killed in the close vicinity of the compound (seealso page 2658 of the NIOD Report). A selection of the war crimes described in theNIOD Report (with references) to which Dutchbat soldiers were witnesses follows.214. Plaintiff refers, inter alia, to page 2650 of the NIOD Report, where it is recorded that inthe course of the afternoon of 12 July 1995 many Dutchbat soldiers heard shots thatcould have pointed to executions.215. During the afternoon of 13 July 1995 a Dutchbat soldier saw five to six VRS soldiersbeat a man with riflebutts. The soldier heard from the closest VRS soldier that he should© Van Diepen Van der Kroef Advocaten 2007www.vandiepen.com93